I had both Mac Studio M1 Max and M2 Max. I did not notice any noise from the latter. Some users will report problem because they can hear something, some unit could have the issue or you should consider many could vote that just for trolling or spreading FUD as always happens.
IMHO the issue was quite noticeable with M1 Max.
Apple has not yet released Acoustic Performance data for the M4 Max or M3 Ultra yet. See below for the M1 Max and M2 Max. The M1 Max clearly had an objectively measurable noise isssue.
I came from a gaming PC with a very expensive closed-loop water cooling setup and it was noisy as hell despite any efforts. The M2 Max Studio is just dead silent pretty much no matter what I have tried. Even Civ 7 with all settings cranked doesn't cause fan noise. Acoustics on the Studio are unmatched in the PC world.